Corrective Action Plans

Finding 1240547 (2025-002)

Material Weakness 2025

PR

Reporting Significant Deficiency

Cognizant or Oversight Agency for Audit: Colegio Catolico Notre Dame Corp. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Gonzalez. Torres & Co., PSC, San Jose Tower 1250 Ponce de Leon Ave. Suite 801...

Cognizant or Oversight Agency for Audit: Colegio Catolico Notre Dame Corp. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Gonzalez. Torres & Co., PSC, San Jose Tower 1250 Ponce de Leon Ave. Suite 801, San Juan, PR 00907-3912 Audit Period: June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT Finding 2025-001: Accounting Records and Reporting System Reportable Condition: See Statement of Condition 2025-001 Recommendation: The Organization should design and implement an integrated accounting system that would allow for the preparation of monthly closings, as well as the preparation of year-end financial statements in accordance with accounting principles generally accepted in the United States of America. Corrective Action – Finding 2025-01 The Organization will implement an integrated accounting closing process, and establish procedures for monthly and year-end closing processes. Management will assign responsible personnel to perform and review the necessary reconciliations, adjustments, and supporting schedules to ensure that the financial records are complete and maintained in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP). Management will also establish a timeline for the monthly and year-end closing process and monitor compliance with the established procedures. FINDINGS – FEDERAL AWARDS Finding 2025-002: Reporting Reportable Condition: See Statement of Condition 2025-002 Recommendation: Management should continue to fulfill their auditee responsibilities as stated in 2 CRF 200.508 which among other things, require management to prepare appropriate financial statements and provide the auditor with access to personnel, accounts, books, records, supporting documentation, and other information as needed for the auditor to perform the audit and to ensure that subsequent financial reporting packages are submitted timely. Corrective Action-Finding 2025-02 Management will ensure that financial statements and required supporting documentation are prepared timely and that the auditor is provided with timely access to personnel, records, accounts, and other information necessary to complete the audit. Management will also monitor the submission of required financial reporting packages to ensure they are submitted within the applicable deadlines. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please contact us at 787-743-3693.

View Audit 414984

Finding 1240544 (2025-002)

Material Weakness 2025

Swope Health Services and Subsidiaries

MO

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.431

Identifying Number: Finding 2025-002 - Fringe Benefit Cost Objectives and Internal Controls Corrective Actions Taken or Planned: A documented actual-to-allocated fringe benefit reconciliation will be prepared and independently reviewed by management before fringe benefit costs are finalized for fede...

Identifying Number: Finding 2025-002 - Fringe Benefit Cost Objectives and Internal Controls Corrective Actions Taken or Planned: A documented actual-to-allocated fringe benefit reconciliation will be prepared and independently reviewed by management before fringe benefit costs are finalized for federal grant reporting and/or requests for reimbursement. The reconciliation and supporting allocation calculation will be retained as evidence that fringe benefit charges are supported, accurate, and appropriately allocated to the applicable federal programs. Person(s) Responsible: Essence Montgomery, CFO and Abdul Hadi, Director of Financial Accounting Anticipated Completion Date: October 1, 2026 Management Oversight & Next Steps: Management will communicate these control requirements to accounting personnel and responsible departments and incorporate them into current accounting policies and procedures. Documentation supporting the performance of each control will be retained as part of applicable workpapers and made available for management review and future audit testing.

View Audit 414983

Finding 1240543 (2025-001)

Material Weakness 2025

Swope Health Services and Subsidiaries

MO

Reporting Matching / Level of Effort / Earmarking § 200.510

Identifying Number: Finding 2025-001 – Schedule of Expenditures of Federal Awards (SEFA) Preparation Corrective Actions Taken or Planned: The completed SEFA and supporting reconciliation will receive a documented secondary management review and approval before submission to the external auditors. Th...

Identifying Number: Finding 2025-001 – Schedule of Expenditures of Federal Awards (SEFA) Preparation Corrective Actions Taken or Planned: The completed SEFA and supporting reconciliation will receive a documented secondary management review and approval before submission to the external auditors. The reviewer will verify the SEFA against the general ledger and grant records, including federal versus non-federal expenditures, ALNs, program clusters, award periods, and total expenditures reported. Evidence of review and approval will be retained with the SEFA workpapers. Person(s) Responsible: Essence Montgomery, CFO and Abdul Hadi, Director of Financial Accounting Anticipated Completion Date: February 1, 2027 Management Oversight & Next Steps: Management will communicate these control requirements to accounting personnel and responsible departments and incorporate them into current accounting policies and procedures. Documentation supporting the performance of each control will be retained as part of applicable workpapers and made available for management review and future audit testing.

View Audit 414983

Finding 1240539 (2025-004)

Material Weakness 2025

Swope Health Services and Subsidiaries

MO

Reporting Subrecipient Monitoring § 200.303 § 200.329

Identifying Number: Finding 2025-004 - Reporting and Internal Controls Corrective Actions Taken or Planned: All required federal financial reports must have documented management review and approval before submission to the granting agency. Evidence of approval, including the reviewer, date of revie...

Identifying Number: Finding 2025-004 - Reporting and Internal Controls Corrective Actions Taken or Planned: All required federal financial reports must have documented management review and approval before submission to the granting agency. Evidence of approval, including the reviewer, date of review, and final report submitted, will be retained with the grant reporting documentation. Reports will not be considered complete until evidence of review and approval has been documented. Person(s) Responsible: Essence Montgomery, CFO and Abdul Hadi, Director of Financial Accounting Anticipated Completion Date: October 15, 2026 Management Oversight & Next Steps: Management will communicate these control requirements to accounting personnel and responsible departments and incorporate them into current accounting policies and procedures. Documentation supporting the performance of each control will be retained as part of applicable workpapers and made available for management review and future audit testing.

View Audit 414983

Finding 1240538 (2025-003)

Material Weakness 2025

Swope Health Services and Subsidiaries

MO

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.302

Identifying Number: Finding 2025-003 - Allowable Costs and Internal Controls Corrective Actions Taken or Planned: No non-payroll expenditure will be charged to a federal award without documented review and approval of the supporting invoice, grant coding, allowability, and confirmation that the expe...

Identifying Number: Finding 2025-003 - Allowable Costs and Internal Controls Corrective Actions Taken or Planned: No non-payroll expenditure will be charged to a federal award without documented review and approval of the supporting invoice, grant coding, allowability, and confirmation that the expenditure has not been charged to another federal award. Supporting documentation and evidence of approval will be maintained with the grant expenditure records to provide a clear audit trail from source documentation to the general ledger and applicable federal award. Person(s) Responsible: Essence Montgomery, CFO; Abdul Hadi, Director of Financial Accounting; and Rushikesh Patel, Accounting Manager Anticipated Completion Date: October 1, 2026 Management Oversight & Next Steps: Management will communicate these control requirements to accounting personnel and responsible departments and incorporate them into current accounting policies and procedures. Documentation supporting the performance of each control will be retained as part of applicable workpapers and made available for management review and future audit testing.

View Audit 414983

Finding 1240535 (2025-002)

Material Weakness 2025

Phac No. 1, Inc.

HI

Management made a deposit of $48,330 on April 21, 2026 to correct the underfunding.

View Audit 414980

Finding 1240534 (2025-001)

Material Weakness 2025

Phac No. 1, Inc.

HI

Management will ensure all documents are provided to the auditor in a timely manner.

View Audit 414980

Finding 1240512 (2025-001)

Material Weakness 2025

Mississippi County Arkansas Economic Opportunity Commission, Inc.

AR

Reporting

View of Responsible Officials and Planned Corrective Action(s): - The Commission’s management understands this finding is required under the rules of the Uniform Aduit Guidance criteria and accepts same. The Commission encountered the perfect storm in the early months of 2025 while starting preparat...

View of Responsible Officials and Planned Corrective Action(s): - The Commission’s management understands this finding is required under the rules of the Uniform Aduit Guidance criteria and accepts same. The Commission encountered the perfect storm in the early months of 2025 while starting preparations for the annual single audit. These events included significant unplanned (long-term experienced) personnel “losses” and shortages, while also implementing new software, as well as battling the challenges of program funding shortages created by the volatile government shutdown early in the year. Overcoming all of the obstacles occurring simultaneously, overcoming the man-power shortage to adequately complete the 2025 year-end single audit reporting package took more time. Management will enhance all procedures to ensure timely filing of all annual reports as required

View Audit 414971

Finding 1240501 (2025-011)

Material Weakness 2025

Heritage University

WA

Student Financial Aid Special Tests & Provisions Material Weakness

11. 2025-011 – Special Tests and Provisions - Verification – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure that verification of students is completed accurately and ac...

11. 2025-011 – Special Tests and Provisions - Verification – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure that verification of students is completed accurately and according to the applicable guidance. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its processes and internal controls surrounding student verification. As part of the University's broader efforts to build capacity within the Financial Aid department, management is reviewing existing verification procedures to ensure requirements are clearly documented, consistently applied, and aligned with applicable federal guidance. The University is establishing clearer ownership of verification responsibilities, defined timelines and checkpoints for completion, and appropriate review procedures to ensure required documentation is obtained and reviewed before verification is considered complete and aid is disbursed. Management will also continue to strengthen staff training and supervisory review and will periodically review procedures as federal requirements change. These efforts are intended to provide greater consistency, accountability, and oversight while ensuring verification requirements are completed accurately and timely. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

View Audit 414959

Finding 1240497 (2025-010)

Material Weakness 2025

Heritage University

WA

Student Financial Aid

10. 2025-010 – Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure that disbursements are accurately applied to student accounts and reported to COD accurately a...

10. 2025-010 – Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure that disbursements are accurately applied to student accounts and reported to COD accurately and timely. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its controls over the disbursement and reporting of Title IV funds. Management is reviewing the processes between Financial Aid and Student Accounts to ensure disbursements are accurately applied to student accounts and reported to COD completely, accurately, and within required timeframes. As part of this work, the University is establishing clearer ownership, defined timelines, and documented checkpoints for reviewing and reconciling disbursement activity between the financial aid system, student accounts, and COD. Responsibilities will be assigned for identifying and resolving discrepancies and ensuring required corrections are completed timely. The University will also incorporate documented review and reconciliation procedures into its Financial Aid processes and continue to evaluate staffing, training, system access, and workload to ensure employees have the capacity and resources necessary to consistently perform these compliance responsibilities. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

View Audit 414959

Finding 1240495 (2025-009)

Material Weakness 2025

Heritage University

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318 § 200.327

9. 2025-009 – Procurement Suspension and Debarment – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University review their current control policies and procedures, and ensure controls are designed and implemented that sat...

9. 2025-009 – Procurement Suspension and Debarment – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University review their current control policies and procedures, and ensure controls are designed and implemented that satisfy the requirements outlined in 2 CFR 200.318 through 200.327 and 2 CFR 180.220. Planned corrective actions: Heritage University agrees with the recommendation and is reviewing its current procurement policies, procedures, and internal controls as they relate to purchases made with federal funds. The University is assessing existing purchasing practices to identify areas where additional documentation, clarification, or controls may be needed to support compliance with applicable federal procurement requirements. As part of this work, management will review responsibilities and coordination among Sponsored Programs, Grant Accounting, the Business Office, Purchasing, and departments responsible for initiating and approving federally funded purchases. The University plans to strengthen and document processes surrounding appropriate approvals, purchasing methods, supporting documentation, vendor review, and other applicable federal requirements. Particular attention will be given to establishing clear ownership and appropriate checkpoints within the purchasing process so that compliance considerations are addressed before federally funded purchases are completed. The Office of Sponsored Programs, in collaboration with the Business Office and other affected departments, will support the review and development of updated procedures and provide guidance and training as processes are established. Management recognizes that strengthening the University's procurement framework will be an ongoing process and will prioritize improvements based on identified risk, operational needs, and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress

View Audit 414959

Finding 1240493 (2025-008)

Material Weakness 2025

Heritage University

WA

Allowable Costs / Cost Principles § 200.430

8. 2025-008 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined...

8. 2025-008 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined in 2 CFR section 200.430(g). Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its internal controls over personnel expenses charged to federal awards and sponsored projects. The University is developing and formalizing procedures to ensure personnel expenses are appropriately authorized, supported by institutional records, accurately allocated to benefiting activities, and periodically reviewed for consistency with federal award requirements. The planned process will establish clear roles and responsibilities among Sponsored Programs, Grant Accounting, Principal Investigators, supervisors, Payroll, Academic Affairs, and other appropriate offices involved in the administration of grant-funded personnel expenses. As part of this work, the University plans to strengthen controls surrounding payroll reconciliation, personnel and funding allocation changes, documentation of work performed, monitoring of payroll distributions, and review of salary cost transfers. Procedures will establish appropriate review and approval requirements, documentation standards, monitoring checkpoints, and processes for identifying and correcting discrepancies. The University is also evaluating its time and effort documentation and certification process to ensure it appropriately supports compensation charged to federal awards and is practical, consistent, and sustainable across the institution. As part of this review, the University is assessing faculty contract and workload structures for faculty who also manage or perform work on sponsored programs to ensure instructional, administrative, and grant-funded responsibilities are appropriately identified and supported. This assessment will include collaboration among Academic Affairs, Sponsored Programs, Human Resources, Payroll, and the Business Office to better align faculty workload, contractual responsibilities, and grant-funded activity. The recently established Office of Sponsored Programs provides additional capacity and centralized oversight for this work. The Director of Sponsored Programs, Compliance & Strategic Initiatives, in collaboration with the Business Office and other affected departments, will lead the development and documentation of these procedures, provide training and guidance to responsible employees, and establish ongoing monitoring practices to assess compliance. Final procedures, responsibilities, review frequencies, and documentation requirements will be established as the University completes its review of current processes and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress

View Audit 414959

Finding 1240486 (2025-007)

Material Weakness 2025

Heritage University

WA

Allowable Costs / Cost Principles § 200.430

7. 2025-007 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined...

7. 2025-007 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined in 2 CFR section 200.430(g). Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its internal controls over personnel expenses charged to federal awards and sponsored projects. The University is developing and formalizing procedures to ensure personnel expenses are appropriately authorized, supported by institutional records, accurately allocated to benefiting activities, and periodically reviewed for consistency with federal award requirements. The planned process will establish clear roles and responsibilities among Sponsored Programs, Grant Accounting, Principal Investigators, supervisors, Payroll, Academic Affairs, and other appropriate offices involved in the administration of grant-funded personnel expenses. As part of this work, the University plans to strengthen controls surrounding payroll reconciliation, personnel and funding allocation changes, documentation of work performed, monitoring of payroll distributions, and review of salary cost transfers. Procedures will establish appropriate review and approval requirements, documentation standards, monitoring checkpoints, and processes for identifying and correcting discrepancies. The University is also evaluating its time and effort documentation and certification process to ensure it appropriately supports compensation charged to federal awards and is practical, consistent, and sustainable across the institution. As part of this review, the University is assessing faculty contract and workload structures for faculty who also manage or perform work on sponsored programs to ensure instructional, administrative, and grant-funded responsibilities are appropriately identified and supported. This assessment will include collaboration among Academic Affairs, Sponsored Programs, Human Resources, Payroll, and the Business Office to better align faculty workload, contractual responsibilities, and grant-funded activity. The recently established Office of Sponsored Programs provides additional capacity and centralized oversight for this work. The Director of Sponsored Programs, Compliance & Strategic Initiatives, in collaboration with the Business Office and other affected departments, will lead the development and documentation of these procedures, provide training and guidance to responsible employees, and establish ongoing monitoring practices to assess compliance. Final procedures, responsibilities, review frequencies, and documentation requirements will be established as the University completes its review of current processes and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress

View Audit 414959

Finding 1240484 (2025-006)

Material Weakness 2025

Heritage University

WA

Student Financial Aid

6. 2025-006 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure the determination of student eligibility for Title IV aid is appropriate and supported. Planned ...

6. 2025-006 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure the determination of student eligibility for Title IV aid is appropriate and supported. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its processes and internal controls surrounding the determination and documentation of student eligibility for Title IV aid. As part of the University's ongoing efforts to build capacity within the Financial Aid department, management is reviewing existing eligibility procedures to clearly define responsibilities, required documentation, and appropriate review checkpoints. The University will establish processes to ensure eligibility requirements are consistently evaluated, adequately supported, and documented prior to the disbursement of Title IV funds. Management will also continue to evaluate staff training, system access, workload, and supervisory review to ensure employees responsible for determining and reviewing eligibility have the knowledge, resources, and capacity necessary to consistently perform these responsibilities. These efforts will be incorporated into documented Financial Aid procedures and periodically reviewed to ensure the controls are operating as intended. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

View Audit 414959

Finding 1240480 (2025-005)

Material Weakness 2025

Heritage University

WA

Student Financial Aid Special Tests & Provisions Material Weakness

5. 2025-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University review their policies and procedures to ensure all withdrawals, including unofficial ...

5. 2025-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University review their policies and procedures to ensure all withdrawals, including unofficial withdrawals where the student does not give formal notification can be identified and accurately evaluated. They also recommend a control be put in place to ensure the calculations and return of funds are performed accurately and timely. Planned corrective actions: Heritage University agrees with the recommendation and is reviewing its withdrawal and Return of Title IV (R2T4) processes to strengthen both the timely identification of student withdrawals and the accurate and timely completion of required calculations and return of funds. The University is reviewing the processes and communication between Financial Aid, the Registrar, Academic Affairs, and other appropriate departments to ensure both official and unofficial withdrawals are identified timely and the information necessary to evaluate a student's withdrawal date is appropriately documented and communicated. Within Financial Aid, responsibilities and timelines will be clearly assigned for reviewing withdrawal information, completing required R2T4 calculations, and returning funds within applicable deadlines. The University will also establish documented review checkpoints to verify that calculations are accurate, required documentation is maintained, and returns are completed timely. As part of its broader efforts to build capacity within Financial Aid, management will continue to evaluate staffing, training, system access, and internal procedures to ensure these compliance responsibilities have clear ownership and appropriate oversight. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

View Audit 414959

Finding 1240477 (2025-004)

Material Weakness 2025

Heritage University

WA

Equipment & Real Property Management § 200.313

4. 2025-004 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation The auditors recommend the University update their equipment tracking system to allow the University to identify assets purchased with federal mo...

4. 2025-004 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation The auditors recommend the University update their equipment tracking system to allow the University to identify assets purchased with federal money. In addition, the auditors recommend the University perform a physical inventory of its fixed asset at least once every two years. Planned corrective actions: Heritage University agrees with the recommendation and recognizes the need to strengthen its processes surrounding the identification, tracking, and monitoring of federally funded equipment. The University is assessing its current practices, records, and systems to better understand existing gaps and determine an appropriate and sustainable process moving forward. This work will include reviewing how federally funded equipment is identified and tracked, clarifying responsibilities across departments, and evaluating opportunities to improve coordination and documentation throughout the lifecycle of an asset. The Office of Sponsored Programs, in collaboration with the Business Office and other affected departments, will assist in developing and documenting appropriate procedures as this assessment progresses. The University will prioritize improvements based on identified risk, available resources, system capabilities, and applicable federal and award requirements. Management recognizes that strengthening this process will require a phased approach and will continue to evaluate and implement improvements as the University's equipment records, processes, and internal controls are reviewed. Name of Responsible Party: Yesenia Rodriguez, Rachel Castilleja, Sagrario Armenta Jimenez, Joanne Fernandez, Aaron Krantz Anticipated completion date: In Progress

View Audit 414959

Finding 1240467 (2025-003)

Material Weakness 2025

Heritage University

WA

Student Financial Aid Reporting Internal Control / Segregation of Duties

3. 2025-003 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: – The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified...

3. 2025-003 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: – The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. They also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its enrollment reporting and monitoring processes. The University is focused on building capacity within the Financial Aid department, clearly assigning responsibility for enrollment reporting activities, and establishing specific timelines and checkpoints to ensure required status changes are identified, reviewed, and submitted within required timeframes. The University is also reviewing the coordination and flow of information between Financial Aid, the Registrar, and other departments involved in student status changes to ensure responsibilities and handoffs are clearly understood. As part of the enhanced monitoring process, designated staff with appropriate NSLDS access will perform periodic spot checks of student enrollment status information to verify that National Student Clearinghouse submissions are accurately reflected in NSLDS. These reviews will be documented, and identified discrepancies will be researched and corrected timely. The Enrollment Alliance group continues to meet on a daily basis. Some of the areas of improvement that have been identified in this group are around system development. We are currently working with IT to explore the options available to support our staff and our processes through our software. Management will continue to evaluate staffing, training, access, and procedures to ensure the department has the capacity and accountability necessary to consistently complete these required compliance activities. Name of Responsible Party: Nancy Benavides, Sagrario Armenta Jimenez Anticipated completion date: Heritage University anticipates implementing the enhanced enrollment reporting procedures and formal NSLDS monitoring controls during Fiscal Year 2026–2027. Once implemented, the monitoring and reconciliation process will continue as an ongoing internal compliance control.

View Audit 414959

Finding 1240465 (2025-002)

Material Weakness 2025

Heritage University

WA

Allowable Costs / Cost Principles § 200.430

2. 2025-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined...

2. 2025-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined in 2 CFR section 200.430(g). Planned Corrective Action: Heritage University agrees with the recommendation and is strengthening its internal controls over personnel expenses charged to federal awards and sponsored projects. The University is developing and formalizing procedures to ensure personnel expenses are appropriately authorized, supported by institutional records, accurately allocated to benefiting activities, and periodically reviewed for consistency with federal award requirements. The planned process will establish clear roles and responsibilities among Sponsored Programs, Grant Accounting, Principal Investigators, supervisors, Payroll, Academic Affairs, and other appropriate offices involved in the administration of grant-funded personnel expenses. As part of this work, the University plans to strengthen controls surrounding payroll reconciliation, personnel and funding allocation changes, documentation of work performed, monitoring of payroll distributions, and review of salary cost transfers. Procedures will establish appropriate review and approval requirements, documentation standards, monitoring checkpoints, and processes for identifying and correcting discrepancies. The University is also evaluating its time and effort documentation and certification process to ensure it appropriately supports compensation charged to federal awards and is practical, consistent, and sustainable across the institution. As part of this review, the University is assessing faculty contract and workload structures for faculty who also manage or perform work on sponsored programs to ensure instructional, administrative, and grant-funded responsibilities are appropriately identified and supported. This assessment will include collaboration among Academic Affairs, Sponsored Programs, Human Resources, Payroll, and the Business Office to better align faculty workload, contractual responsibilities, and grant-funded activity. The recently established Office of Sponsored Programs provides additional capacity and centralized oversight for this work. The Director of Sponsored Programs, Compliance & Strategic Initiatives, in collaboration with the Business Office and other affected departments, will lead the development and documentation of these procedures, provide training and guidance to responsible employees, and establish ongoing monitoring practices to assess compliance. Final procedures, responsibilities, review frequencies, and documentation requirements will be established as the University completes its review of current processes and applicable federal requirements. Name of Responsible Party: • Director of Sponsored Programs • Grant Accountant Anticipated Completion Date: In Progress

View Audit 414959

Finding 1240453 (2025-015)

Material Weakness 2025

Guam Department of Education

GU

Matching / Level of Effort / Earmarking

Finding No.: 2025-015 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $0 Views...

Finding No.: 2025-015 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $0 Views of Auditee and Corrective Actions The Guam Department of Education (GDOE) disagrees with the finding and the associated projected deficiency. GDOE maintains its position that expenditures identified and reported toward the ARP-OA SEA 20% earmarking requirement were incurred in support of activities intended to address the academic impact of lost instructional time and the implementation of GDOE's approved educational interventions. The July 2023 U.S. Department of Education FAQ A-4.b clarifies that expenditures qualifying toward the ARP-OA SEA requirement are not limited to the direct cost of delivering an evidence-based intervention. Reasonable and necessary activities and costs associated with implementing an evidence-based strategy that advances the purpose of addressing the academic impact of lost instructional time may also be included. Each PO's supporting documentation in Munis includes a Determination of Need form that provides justification that may directly or indirectly connect the expenditure with activities that were deemed to address learning loss. To resolve this finding, GDOE will work with the granting agency to obtain a Program Determination letter outlining the specific deficiencies noted in the audit finding relative to the 20% requirement.

View Audit 414946

Finding 1240452 (2025-014)

Material Weakness 2025

Guam Department of Education

GU

Equipment & Real Property Management § 200.313

Finding No.: 2025-014 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Equipment and Real Property Management Questioned Costs: $5,268 ...

Finding No.: 2025-014 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Equipment and Real Property Management Questioned Costs: $5,268 Views of Auditee and Corrective Actions GDOE agrees with the finding. The finding identified that the acquisition cost for Asset No. 103192, a PIONEER 48,000 BTU A/C split unit, was recorded in the property record as $5,268.00 instead of the supported invoice cost of $4,684.05. The asset record was corrected on August 25, 2026, to reflect the verified acquisition cost. Receiving and Property Management acknowledge the importance of ensuring that property records are complete, accurate, and supported by appropriate source documentation in accordance with 2 CFR 200.313(d). The incorrect acquisition cost resulted from the inconsistent submission of supporting documents to the Receiving Warehouse Supervisor, which created unclear guidance regarding the correct acquisition cost to be recorded. Plan of action and completion date: Asset No. 103192 was corrected in the property record from $5,268.00 to the verified invoice cost of $4,684.05. The correction was completed on August 25, 2026. Plan to monitor and responsible officials: The Receiving Warehouse Supervisor II will ensure that all required supporting documentation is received and reviewed before approving the Receiving Report for submission to the Property Management Office. The review will include verification of the quantity received, unit acquisition cost, asset description, and other information necessary to properly identify and record the asset. The Receiving Warehouse Supervisor II, Inventory Management Officer, Property Control Officers, and Supply Management Administrator will be responsible for implementing and monitoring corrective actions.

View Audit 414946

Finding 1240451 (2025-016)

Material Weakness 2025

Guam Department of Education

GU

Special Tests & Provisions Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding No.: 2025-016 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund 84.425A Education Stabilization Fund – State Educational Agency (Outlying Areas) Federal Award No.: S425A210003 Area: Special Tests and Provisions – Wage Rate Requirements Questioned Co...

Finding No.: 2025-016 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund 84.425A Education Stabilization Fund – State Educational Agency (Outlying Areas) Federal Award No.: S425A210003 Area: Special Tests and Provisions – Wage Rate Requirements Questioned Costs: $4,255,458 Views of Auditee and Corrective Actions GDOE concurs with the recommendation that controls over compliance with applicable Wage Rate Requirements should be strengthened. GDOE was not aware of the broader factors that would trigger the Davis-Bacon requirement. All the training and webinars GDOE program personnel attended iterated the requirement when federal funds are used for construction projects. However, GDOE does not concur with the determination that the entire $4,255,458 associated with the identified construction project constitutes questioned costs. GDOE acknowledges that the required certified payroll documentation was not maintained for the transactions identified in the finding. GDOE further acknowledges the need to strengthen its procurement and contract administration procedures to ensure that federally funded construction activities subject to applicable Wage Rate Requirements contain the required contractual provisions and that certified payroll documentation is obtained, reviewed, and retained. However, the absence of an executed construction contract and certified payroll documentation does not, by itself, establish that the entire amount paid to the vendor was unallowable or that workers performing the work were compensated below applicable wage requirements. Accordingly, GDOE believes that the questioned-cost determination should distinguish between the identified compliance and documentation deficiency and evidence demonstrating that the underlying expenditures were unallowable. GDOE will continue its efforts to obtain available certified payrolls, payroll records, and other supporting documentation from the contractor and will provide such documentation for consideration during audit resolution. Plan of action and completion date: GDOE will strengthen controls over federally funded construction projects subject to applicable Wage Rate Requirements. GDOE will: 1. Establish a documented determination of the applicability of Wage Rate Requirements for federally funded construction activities prior to solicitation, award, purchase order issuance, or commencement of work. 2. Ensure that solicitations, contracts, purchase orders, and other applicable procurement documents contain all required federal labor standards and Wage Rate Requirements provisions when applicable. 3. Require contractors and subcontractors subject to Wage Rate Requirements to submit required certified payroll documentation within the applicable timeframe during contract performance. 4. Designate responsible personnel to review certified payroll submissions for completeness and compliance and document evidence of the review. 5. Develop and implement a standardized compliance checklist for federally funded construction projects addressing Wage Rate Requirements, required contract provisions, certified payroll submissions, and related documentation. 6. Maintain certified payrolls, applicable wage determinations, contract provisions, compliance reviews, and other supporting documentation within the applicable procurement or contract file. 7. Provide guidance and training to Procurement, Federal Programs, project managers, contract administrators, and other personnel involved in federally funded construction activities regarding Wage Rate Requirements and documentation responsibilities. 8. Continue efforts to obtain the outstanding certified payrolls, payroll records, and other supporting documentation for the project identified in the finding and document the final resolution of the matter. Corrective actions will begin with immediate implementation for new federally funded construction activities subject to Wage Rate Requirements. Remediation of the transactions identified in the finding remains ongoing pending receipt and review of available contractor payroll documentation. Plan to monitor and responsible officials: Procurement Division, Federal Programs Division, applicable project/program managers and contract administrators, and Financial Affairs as applicable will be responsible for corrective action implementations and monitoring.

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Finding 1240450 (2025-013)

Material Weakness 2025

Guam Department of Education

GU

Procurement, Suspension & Debarment § 200.317 § 200.318 § 200.324 § 200.327

Finding No.: 2025-013 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A230002, S403A240002 Area: Procurement and Suspension and Debarment Questioned Costs: $2,284,786 Views of Auditee and Corrective Actions GDOE agrees with the finding and r...

Finding No.: 2025-013 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A230002, S403A240002 Area: Procurement and Suspension and Debarment Questioned Costs: $2,284,786 Views of Auditee and Corrective Actions GDOE agrees with the finding and recommendations regarding cost or price analysis and suspension and debarment requirements. GDOE recognizes that its procurement policies should clearly address the requirement to perform and document cost or price analyses for applicable procurements and contract modifications exceeding the simplified acquisition threshold. GDOE also acknowledges that its existing procedures did not require suspension and debarment verification on a per covered transaction basis or provide sufficient documentation of the verification performed. Although the vendors selected for the transactions identified in the finding were not suspended or debarred as of September 30, 2025, GDOE recognizes that the required verification was not performed and documented prior to entering into the covered transactions. GDOE will strengthen its policies and internal controls to address these requirements. Plan of action and completion date: GDOE recognizes that procurement procedures should be reviewed periodically to ensure that applicable federal requirements are incorporated and that adequate controls are in place to demonstrate compliance. GDOE Supply Management Office will: 1. Review and update procurement policies to address the requirements of 2 CFR 200.324 for cost or price analysis. 2. Establish procedures and standardized documentation for cost or price analyses, including applicable contract modifications. 3. Establish a formal process requiring suspension and debarment verification before entering into each covered transaction. 4. Require documentation of the verification, including the vendor, date, method, and results, to be retained in the procurement file. 5. Provide training to applicable procurement and program personnel on these requirements. 6. Periodically review procurement policies and files to ensure compliance with federal requirements. Corrective actions will be completed by December 2026. Plan to monitor and responsible officials: GDOE Office of Supply Management will be responsible for implementing and monitoring the corrective actions. Periodic procurement file reviews will be performed to verify that required cost or price analyses and suspension and debarment verifications are completed and documented.

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Finding 1240449 (2025-012)

Material Weakness 2025

Guam Department of Education

GU

Equipment & Real Property Management § 200.313

Finding No.: 2025-012 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A230002 Area: Equipment and Real Property Management Questioned Costs: 3,095 Views of Auditee and Corrective Actions GDOE agrees with the finding. The finding identified t...

Finding No.: 2025-012 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A230002 Area: Equipment and Real Property Management Questioned Costs: 3,095 Views of Auditee and Corrective Actions GDOE agrees with the finding. The finding identified that the acquisition cost for asset no. 103166, a Motorola APX 4000 radio, was recorded in the property record as $3,095.00 instead of the supported invoice cost of $1,319.14. The asset record was corrected on August 26, 2026, to reflect the verified acquisition cost. GDOE acknowledges the importance of ensuring that property records are complete, accurate, and supported by appropriate source documentation in accordance with 2 CFR 200.313(d). The following corrective action plan addresses the finding and strengthens the review of asset costs from receipt through final entry into the property records. Plan of action and completion date: Asset No. 103166 was corrected in the property record from $3,095.00 to the verified invoice cost of $1,319.14. The correction was completed on August 26, 2026. Plan to monitor and responsible officials: The Receiving Warehouse Supervisor II will review the purchase order, vendor invoice, and related receiving documentation before approving the Receiving Report for submission to the Property Management Office. The review will include verification of the quantity received, unit acquisition cost, description, and other information necessary to properly identify the asset. The Receiving Warehouse Supervisor II, Inventory Management Officer, Property Control Officers, and Supply Management Administrator will be responsible for implementing and monitoring corrective actions.

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Finding 1240448 (2025-011)

Material Weakness 2025

Guam Department of Education

GU

Allowable Costs / Cost Principles Cash Management Subrecipient Monitoring

Finding No.: 2025-011 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A220002, S403A230002, S403A240002 Area: Cash Management Questioned Costs: 841,180 Views of Auditee and Corrective Actions GDOE does not agree on the criteria and the cause...

Finding No.: 2025-011 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A220002, S403A230002, S403A240002 Area: Cash Management Questioned Costs: 841,180 Views of Auditee and Corrective Actions GDOE does not agree on the criteria and the cause. The requirement that vendors for federal expenditures are paid either on the same day or within 24 hours after the funds had been received, was a requirement for the TPFA. This requirement was removed in reference to the letter from US Department of Education dated July 19, 2024, wherein the special condition regarding vendor payments was removed. All items comprising the $841,180 questioned cost were all paid within three business days from the date of the drawdown, therefore demonstrating GDOE’s commitment to minimize the time between the drawdown of federal funds and their disbursement. Plan of action and completion date: GDOE will revisit existing SOP on Cash Disbursement Procedures to reflect the Department's current responsibilities following the transition from the TPFA and incorporate applicable U.S. Department of Education Special Conditions and other cash management requirements into GDOE’s written procedures. Plan to monitor and responsible officials: The Federal Programs Division and Financial Affairs Accounts Payable will be responsible for monitoring the implementation of corrective actions. The SOP will be updated during FY2026, with monitoring and compliance procedures ongoing thereafter.

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Finding 1240447 (2025-010)

Material Weakness 2025

Guam Department of Education

GU

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment

Finding No.: 2025-010 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A240002 Area: Allowable Costs/Cost Principles Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE agrees with the finding and acknowledges the need to streng...

Finding No.: 2025-010 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A240002 Area: Allowable Costs/Cost Principles Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE agrees with the finding and acknowledges the need to strengthen internal controls governing the review and processing of Consolidated Grant funded requisitions. As identified in the finding, a random sample of requisitions associated with newly created project account codes did not route to the required Federal Programs reviewer because the applicable workflow had not been established properly. Plan of action and completion date: The Federal Programs Division, Financial Affairs, Procurement Office and FSAIS have coordinated together to address the identified routing deficiency. The Procurement Office is reviewing the system workflow for Consolidated Grant funded requisitions and identifying any requisitions that did not receive the required Federal Programs Division approval. For any such requisition, the Federal Programs Division conducts the required compliance review and provides written confirmation of its determination, which is then attached to the requisition record in MUNIS. Financial Affairs has also coordinated with FSAIS to review and correct the MUNIS workflow to ensure that requisitions generated and routed moving forward are directed to the appropriate Federal Programs Division reviewer before proceeding to the Procurement Office for processing. Plan to monitor and responsible officials: The Procurement Office, FSAIS and Federal Programs Division will periodically review federally funded requisition routing to ensure required workflow steps remain in place and processing does not proceed without the approvals required under GDOE procedures. Identified routing or approval deficiencies will be referred to the appropriate office for correction and follow-up. The Procurement Office will be responsible for ensuring required approvals are completed prior to processing requisitions, FSAIS for maintaining the appropriate system workflow and the Federal Programs Division will be responsible for continuing to conduct compliance reviews. Corrective actions to address the identified routing deficiency have been implemented as of September 2026. The Procurement Office and FSAIS have completed the initial workflow review and corrective measures, and the Federal Programs Division has begun reviewing and documenting affected requisitions as needed. Ongoing monitoring by the Procurement Office and periodic randomized reviews by the Federal Programs Division will continue as part of regular operations.

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Corrective Action Plans

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